Structural Fiscalistics Meets OECD Pillar Two: Rendering GloBE as Executable Institutional Routing

This paper examines OECD Pillar Two not primarily as a doctrinal set of tax rules but as an institutional execution system operating through repeated cross-border interfaces such as calculation, reporting, verification, allocation, and filing coordination. When these interfaces interact with heterogeneous domestic tax infrastructures, structural stress may arise from differences in accounting bases, classification systems, and administrative pathways. To make these interactions analytically observable, the paper introduces a structural reading method grounded in Structural Fiscalistics. The framework proposes a minimal institutional existence condition expressed as F = X × Y under going concern, where the X-axis represents cross-jurisdictional fiscal openness and the Y-axis represents continuity of post-tax capacity over time. This condition functions as a threshold test determining whether a fiscal configuration remains a stable object of institutional analysis. At the execution layer, the paper applies the 4-3-3-2 grammar as a diagnostic rendering protocol that decomposes fiscal configurations into inputs, containers, conversions, and triggers. This grammar allows Pillar Two processes to be represented as routable institutional paths rather than purely narrative interpretations. The paper’s contribution is methodological rather than normative. It provides a reproducible rendering protocol—linking visibility, routing structure, and admissibility discipline—that enables analysts to document, compare, and audit Pillar Two execution across jurisdictions without presupposing specific policy conclusions.